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The U.S. Department of Justice recently revealed the criteria for disclosure of account information made in the August 19, 2009, U.S.-Swiss Treaty Request, under the U.S.-Swiss tax treaty.

The IRS currently offers the following five programs for noncompliant taxpayers: (i) the Offshore Voluntary Disclosure Program (OVDP), (ii) Streamlined Domestic Offshore Procedures...

The dust is beginning to settle on the effect and fate of SAFE Circular 11 and Circular 29, at least for the time being. On October 21, 2005, SAFE issued the long awaited new circular on "Relevant Issues Concerning Foreign Exchange Control on Domestic Residents' Corporate Financing and Roundtrip Investment Through Offshore Special Purpose Vehicles"

On April 4, 2016, the Treasury Department and the Internal Revenue Service issued a sweeping package of new regulations intended to curtail inversion transactions

Many U.S. taxpayers express bravado with respect to their records in foreign countries, commonly exclaiming "the IRS can’t get that—it’s overseas".

A summary of the responses of DMS Offshore Investment Services to the July Consultation and Guidance.